Clyde E. Owens and Marie W. Owens - Page 15

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          provide those documents at that time because they could not                 
          identify which of the materials they brought to trial Poole had             
          seen.  Thus, the Court told petitioners that it would admit into            
          evidence documents that Poole had seen if petitioners served                
          copies of them on the Court and respondent's counsel within 30              
          days after the trial.2                                                      
                                    II.  OPINION                                      
               Respondent's determinations in the notices of deficiency are           
          presumed to be correct, and petitioners bear the burden of                  
          proving otherwise.  Rule 142(a); Welch v. Helvering, 290 U.S.               
          111, 115 (1933).                                                            
          A.   Petitioners' Constitutional and Other Contentions                      
               Petitioners contend that respondent's agents have been                 
          abusive to petitioners and that respondent has violated several             
          of petitioners' rights under the U.S. Constitution and Civil                
          Rights Acts of 1963 and 1964.                                               

               1.   Events Before and During The Audit                                
               Petitioners contend that respondent's agents were abusive to           
          them before and during the audit of these cases.  Petitioners               
          contend that respondent's agents had a personal vendetta against            
          them.  Mr. Owens testified that he had a confrontation with an              

               2 Respondent did not object to the admission of these                  
          documents under this procedure.                                             

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